Xscale Lancamentos LTDA

Data Classification and Encryption Policy

Effective date: November 6, 2026 · Owner: Carlos Henrique Ferreira Guimaraes · Reviewed every 12 months or after any material change

Classes

ClassExamplesHandling
RestrictedApp secret, OAuth access/refresh tokens, account passwordsEncrypted at rest, never in source control or logs, owner-only access
ConfidentialAffiliate order and commission reports, account analyticsKept on the operator workstation only, used for internal reporting
InternalProduct lists, scripts, content draftsCompany systems only
PublicWebsite, published videosNo restriction

Personal data

Xscale does not collect or store TikTok buyers' personal data (names, addresses, phone numbers). If an API response ever contains it, it is not persisted.

Encryption

Retention

Restricted data is deleted when no longer needed; reports are kept for up to 5 years for tax purposes, then deleted.

Approved by Carlos Henrique Ferreira Guimaraes, Managing Partner, on November 6, 2026.